The REIQ contract is not your AML program
The REIQ contract is the sale contract, not your AML/CTF program, and a special condition does not enrol the agency or appoint a compliance officer.
Quick answer
A clause that asks a party to provide identity details may allocate a task on that sale, and it does not assess your risks, approve your program, or decide which services are designated. The Queensland agency still keeps a program. This page does not draft special conditions and it does not reproduce the contract. The client pays a check the program requires.
People search “REIQ contract AML special conditions” when a Queensland agency adds a special condition about identity documents and treats the contract as the AML program. Checked against AUSTRAC’s real estate examples on dealing with customers on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. How the program is written is the AML/CTF program for Tranche 2. The agency-wide picture is real estate AML compliance. The sector map is /tranche-2.
A clause is not a program
The REIQ contract governs the sale between the parties, and an AML/CTF program governs how the agency meets its obligations. A special condition can say, for that sale, that a party will provide something, and it cannot enrol you, name your compliance officer, or record your risk assessment. AUSTRAC’s examples of dealing with customers belong to the program world. This page does not reproduce them or the contract.
The Queensland agency keeps both documents. Sales staff can point at the clause when they ask for what the program already requires. They cannot point at the clause when a reviewer asks for the program. If the clause and the program disagree, the disagreement is a problem to fix in the program, not a reason to follow the clause alone.
- Leave enrolment off the contract. Enrolment is the business’s act with AUSTRAC. A buyer’s signature does not do it.
- Leave the officer off the contract. The compliance officer is appointed in the program. A special condition that names the agent is not that appointment.
- Do not draft the clause here. This page will not supply wording. Contract wording is for the firm’s own process, and it is not the program.
- Match the clause to a program step. If you ask for identity material, the program should already say why. A surprise clause is how files diverge.
Contract, program, check
Three pieces of paper feel like one job on exchange day. They are three jobs. Name the one you are doing.
A sorting aid for a Queensland sale. This table does not reproduce the REIQ contract or AUSTRAC’s customer examples.
| Document | What it can do | What it cannot do |
|---|---|---|
| REIQ contract | Record the bargain, including a special condition | Be the AML/CTF program |
| Special condition about identity | Allocate a task on this sale, if you use one | Enrol the agency or approve a risk assessment |
| The agency’s program | Say which services and which customer steps apply | Update itself because a clause was added |
| The client-pays check | The verification the program required | Become done because the contract asked for “ID” |
Where the contract page stops
This page keeps the REIQ contract out of the program slot. It is not how to write the program and it is not the whole agency guide. Those are the AML/CTF program for Tranche 2 and real estate AML compliance.
What the client pays
On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. A special condition is not included in the firm suite, and the suite does not turn a contract clause into a program. Confirm the live amounts on FreeAML pricing. FreeAML does not draft a special condition or treat the REIQ contract as your program.
📚 Related Resources
Real Estate AML Toolkit →
Complete compliance toolkit for property agents.
Real Estate AML Guide →
Everything agents need to know about Tranche 2.
Free KYC Check →
Verify customer identity in 60 seconds. Government ID + AML screening.
Free AML Program →
Board-ready AML/CTF Program template. All 10 AUSTRAC sections included.
Risk Assessment Generator →
AI-powered ML/TF risk assessment. 20-page compliant report in 5 minutes.
Free AML Training →
Online courses for staff. CPD-certified certificates included.
Frequently Asked Questions
Keep the contract and the program as two documents.
The firm suite is A$0. The client pays a check the approved program requires. The contract does not replace that program.
Open the Tranche 2 guideQuestions: team@freeaml.com.au